COMMON HRSA COMPLIANCE QUESTIONS: Clinical Staffing – NPDB Queries

The HRSA Site Visit Protocol states (Clinical Staffing, Element c. question 5.2) that a health center should complete a “query through the NPDB”. A common question regarding this topic is, “Does this include unlicensed or uncertified clinical staff (Other Clinical Staff or “OCS”)"?”.

Some health centers interpret this to mean that the health center must run National Practitioner Data Bank (NPDB) queries on their provider staff (LIPs) and some of their Other Licensed of Certified Practitioners (OLCPs) staff: RNs, LPNs, CMAs, RDs, or Pharmacists).

If you look at the first part of the compliance question cited above, you’ll see that it asks if this is done “for all clinical staff upon hire AND on a recurring basis”.

Additionally, the FTCA Credentialing and Privileging Tool states that, “The health center is required to register for the NPDB and query the NPDB for all health center staff (LIPs, OLCPs, and OCS)”.

So, given the above information, our recommendation is to complete a query through the NPDB upon hire and on a recurring basis for all clinical staff (LIPs, OLCPs, and “Other Clinical Staff”) who are directly employed, independently contracted, or volunteers.

**Editor's Note: On February 27, 2020, HRSA clarified the HRSA Site Visit Protocol to remove the phrase, "...for NPDB-reportable provider types" from the question mentioned above. This clarifies that NPDB queries should be completed for all clinical staff (LIPs, OLCPs, and Other Clinical Staff).